Shippers are still coming to grips with the recent International Civil Aviation Organization (ICAO) addendum, which among other changes, established the first-ever state-of-charge limitation on air transport of lithium batteries.
Then, on Saturday, January 16th, the International Air transport Association (IATA) released an addendum to 57th edition of the Dangerous Goods Regulations, commonly referred to as the DGR. And if you ship Lithium Batteries of any type, you should know that:
- It may be ill-advised to assume that things have remained static. Review your current practice in light of the new restrictions.
- It is now the case that requirements can differ significantly between carriers.
- It is likely that restrictions will continue to increase.
- It is likely that costs associated with shipping may rise commensurately.
- You should develop an alternate shipping plan to execute in case an outright ban by air
Here are the specified changes to packing instructions (PI), in order of impact:
Airline restrictions include outright bans.
A very large number of airline variations appear which feature either very significant restrictions or even outright bans on the carriage of lithium batteries of either or both types (i.e. Ion/Polymer or Metal) aboard passenger and in a few cases even cargo aircraft. Consult the new Addendum for details.
Airline variations are “custom” modifications to the regulations made by either states (countries) or air carriers to better suit their own needs and priorities. With so many individual airlines banning so many types of lithium battery carriage, one wonders if an industry-wide ban on air carriage isn’t being considered in some quarters.
The new 30% state-of-charge restriction is added.
PI 965 is changed to incorporate both the new 30% state-of-charge (SOC) restriction as well as a mandated limit of one package per consignment for batteries falling under Section II. Additionally, there is clarifying language related to overpacks.
Battery manufacturers can test the state-of-charge of their products, but downstream resellers and retailers are hardly equipped to do so. And how will the instructions be enforced? Will carriers actually open packages to test the batteries within?
Also echoing the recent ICAO addendum are PI 968, limiting consignments and overpacks to only one package apiece, and PI 970, clarified to require rigid outer packagings.
Instructions for battery powered equipment/vehicles are revised—confusingly.
PI 952, dealing with UN 3171 Battery Powered Equipment/Vehicles, is revised to:
- provide more comprehensive packaging type selections for outer packagings
- provide additional cautions for securement
- specifically forbidding damaged or defective lithium batteries
However, note what appears to be potentially confusing language. Special Provision (SP) A21 has instructions that on the surface appear to require the reclassification of vehicles containing lithium batteries from UN 3171 to UN 3480/3481/3090/3091. But, if this is the case, then how do shippers observe the subsequent additional instructions in PI 952, since the items in question would no longer be UN 3171?
A bit deeper in the SP there is some potential clarification—this clause applies to equipment, and not to vehicles per se. It is still a very grey area, however, and shippers should carefully consider both the SP and the way that their materials or products may relate to it before consigning their shipment.
Note that both United Parcel Service (Limitation 5X-07) and Air Canada (Limitation AC-08) also address these handling issues.
The whole thing appears aimed at addressing items such as hoverboards, which have been much in the news of late due to alleged failures in their onboard lithium battery power sources.
UPS imposes new requirements.
UPS 5X-07 imposes anew prior approval requirements for:
- lithium batteries falling under SP’s A88, A99, or A183
- refurbished lithium batteries
The limitation also notes that batteries prepared for shipment under PI 965 Section II—the 30% state-of-charge restriction—may be returned to shippers further downstream from UPS routings.
This is another reason why it is important to verify your package’s routing across all carriers before offering such a consignment for transport.
Count on Labelmaster, a full-service provider of products, software, and consulting expertise across the Dangerous Goods and EH&S Industry’s spectrums of need, to stay on top of the changes that will affect you most as the shipper. Visit www.labelmaster.com.
For more information about these regulatory updates, please contact Nikki Burgess, Labelmaster’s staff regulatory specialist.